FUNDING APPROVAL AGREEMENTPt tEwrop
7�a* J"LL,!UJ,� * Np
GAeAN DEN/OP
October 3rd, 2018
Honorable George N Cretekos
Mayor of the City of Clearwater
Post Office Box 4748
112 S Osceola Ave
Clearwater, FL 33758-4748
U. S. Department of Housing and Urban Development
Jacksonville Field Office
Charles Bennett Federal Building
400 West Bay Street
Suite 1015
Jacksonville, Florida 32202-4410
-i-ii --‘
OCT 0 9 2u1S
By C ,
SUBJECT: Fiscal Year 2018 Action Plan and Grant Approvals
For the City of Clearwater, Florida
Dear Mayor Cretekos:
The Fiscal Year 2018 Action Plan submitted by the City of Clearwater has been reviewed
by HUD and approved. Based on this approval, I am pleased to transmit to you Fiscal Year 2018
grant agreements for the following program contained in your Plan:
Community Development Block Grant (CDBG) - $740,943
HOME Investment Partnerships Program - $383,146
The program year for the above grants is October 1, 2018 through September 30, 2019.
Enclosed are the grant agreements, to be signed and dated by the City of Clearwater, for the
programs contained in your Action Plan. After signing, please return one original grant
agreement to this Office and retain the second for your records.
Please note the below requirements for this program year that have changed. CDBG
funds may not be provided to a for-profit entity pursuant to section 105(a)(17) of the Act unless
such activity or project has been evaluated and selected in accordance with Appendix A to 24 CFR
570 - "Guidelines and Objectives for Evaluating Project Costs and Financial Requirements."
(Source - P.L. 113-235, Consolidated and Further Continuing Appropriations Act, 2015, Division
K, Title II, Community Development Fund).
The CDBG program continues to improve neighborhoods, provide decent housing, and
create new economic opportunities, with special focus on serving low -and moderate -income
persons. The program's success is the result of strong partnerships among elected officials at all
levels of government, neighborhood based nonprofit organizations, private sector, and HUD. We
thank you for your continued service and cooperation to ensure that the CDBG program thrives
far into the future.
As a part of the mandate from Congress to administer the CDBG program, HUD
determines annually whether each CDBG Entitlement Community is carrying out its activities "in
HUD's mission is to increase homeownership, support community
development and increase access to affordable housing free from discrimination.
www.hud.gov espanol.hud.gov
a timely manner". We are pleased to announce that your community has once again met this
standard. This is a significant accomplishment and we thank you for all of your hard work and
dedication.
We also congratulate you and your staff on the preparation of your Action Plan and look
forward to working with you over the coming year to accomplish the goals set forth for your
community and to further refine and improve your Consolidated Plan. If you have any questions
or require further information or assistance, please contact, Larry Lopez, Senior Community
Planning and Development Representative at (904) 208-6008 or by email at
Larry.M.Lopez@'hud.gov.
Very sincerely yours
Tom Bilodeau, Program Manager, Community
Planning and Development Division, 4HD
Enclosure: Grant Agreements
00ENToF
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Good Day,
U. S. Department of Housing and Urban Development
Jacksonville Field Office
CPD Division, 4HD
Charles Bennett Federal Building
400 West Bay Street, Suite 1015
Jacksonville, Florida 32202-4410
These copies of the fully executed, signed
and dated Grant Agreement are YOUR COPIES
for your records.
Kevin P Chung
Financial Analyst
U.S. Department of Housing and Urban Development
Office of Community Planning and Development
400 West Bay Street, Suite 1015
Jacksonville, FL 32202
Phone: (904) 208-6116
Email: kevin.p.chungL-hud.gov
HUD's mission is to increase homeownership, support community
development and increase access to affordable housing free from discrimination.
www.hud.gov espanol.hud.gov
Funding Approval/Agreement
Title I of the Housing and Community
Development Act (Public Law 930383)
HI -00515R of 20515R
U.S. Department of Housing and Urban Development
Office of Community Planning and Development
Community Development Block Grant Program
OMB Approval No. 2506-0193
exp 5/31/2018
1. Name of Grantee (as shown in item 5 of Standard Form 424)
[ g n th rr•1T13t , C/ry DG 4Br4AO*fa �G r'LDZ+O.I
2. Grantee's Complete Address (as shown in item 5 of Standard Form 424)
PO Box 4748
Clearwater, FL 33758-4748
3a. Grantee's 9 -digit Tax ID Number
596000289
3b. Grantee's 9 -digit DUNS Number
078307303
4. Date use of funds may begin
10/01/2018
5a. Project/Grant No. 1
B -18 -MC -12-0002
5b. Project/Grant No. 2
6a. Amount Approved
$740,943.00
6b. Amount Approved
Grant Agreement: This Grant Agreement between the Department of Housing and Urban Development (HUD) and the above named Grantee is made pursuant to the
authority of Title I of the Housing and Community Development Act of 1974, as amended, (42 USC 5301 et seq.). The Grantee's submissions for Title I assistance, the
HUD regulations at 24 CFR Part 570 (as now in effect and as may be amended from time to time), and this Funding Approval, including any special conditions, constitute
part of the Agreement. Subject to the provisions of this Grant Agreement, HUD will make the funding assistance specified here available to the Grantee upon execution
of the Agreement by the parties. The funding assistance specified in the Funding Approval may be used to pay costs incurred after the date specified in item 4 above
provided the activities to which such costs are related are carried out in compliance with all applicable requirements. Pre -agreement costs may not be paid with funding
assistance specified here unless they are authorized in HUD regulations or approved by waiver and listed in the special conditions to the Funding Approval. The Grantee
agrees to assume all of the responsibilities for environmental review, decision making, and actions, as specified and required in regulations issued by the Secretary
pursuant to Section 104(g) of Title I and published in 24 CFR Part 58. The Grantee further acknowledges its responsibility for adherence to the Agreement by sub -
recipient entities to which it makes funding assistance hereunder available.
U.S. Department of Housing and Urban Development (By Name)
Tom Bilodeau
Grantee Name
C,r'y DI'GI-4•i 4 kail464
Title
Program Manager
Title FLAG 04
Ci Pi 4 40W44F4
Signature VL._.____Date
(mm/dd/yyyy)
10/03/2018
Signature
10-1.1.4,44A.,....
Date (mm/dd/yyyy)
7. Category of Title I Assistance for this Funding Action:
Entitlement, Sec 106(b)
'
8. Special Conditions
(check one)
• None
9a. Date HUD Received Submission
08/13/2018
10. check
one
Orig. Funding
Approval
Amendment
Amendment Number
0 a.
9b. Date Grantee Notified
10/03/2018
0 Attached
• b.
9c. Date of Start of Program Year
(10/01/2018)
11. Amount of Community Development
Block Grant
FY (2018)
FY (2017)
FY ( )
a. Funds Reserved for this Grantee
$740,885.00
$ 58.00
b. Funds now being Approved
c. Reservation to be Cancelled
(11a minus 11b)
12a. Amount of Loan Guarantee Commitment now being Approved
N/A
12b. Name and complete Address of Public Agency
C9 iv Oi' C cEA.t i4) 4r , •FL,.
PO Box 4748
Clearwater, FL 33758-4748
Loan Guarantee Acceptance Provisions for Designated Agencies:
The public agency hereby accepts the Grant Agreement executed by the
Department of Housing and Urban Development on the above date with
respect to the above grant number(s) as Grantee designated to receive loan
guarantee assistance, and agrees to comply with the terms and conditions
of the Agreement, applicable regulations, and other requirements of HUD
now or hereafter in effect, pertaining to the assistance provided it.
12c. Name of Authorized Official for Designated Public Agency
di4
Title
Signature
HUD Accounting use Only
Batch TAC Program Y A Reg Area Document No.
1
5
3
1
7
6
Project Number Category
Project Number
Project Number
Amount
Amount
Amount
Effective Date
(mm/dd/yyyy) F
Date Entered PAS (mm/dd/yyyy)
Date Entered LOCCS (mm/dd/yyyy)
Batch Number
Transaction Code
Entered By
Verified By
24 CFR 570
form HUD -7082 (5/15)
8. Special Conditions.
(a) The period of performance for the funding assistance specified in the
Funding Approval ("Funding Assistance") shall begin on the date
specified in item 4 and shall end on September 1, 2025. The Grantee
shall not incur any obligations to be paid with such assistance after
September 1, 2025.
(b) The Recipient shall attach a schedule of its indirect cost rate(s) in the
format set forth below to the executed Agreement that is returned to
HUD. The Recipient shall provide HUD with a revised schedule when
any change is made to the rate(s) described in the schedule. The
schedule and any revisions HUD receives from the Recipient shall be
incorporated herein and made a part of this Agreement, provided that the
rate(s) described comply with 2 CFR part 200, subpart E.
Administering Direct
Department/Agency Indirect cost rate Cost Base
Instructions: The Recipient must identify each agency or department of the
Recipient that will carry out activities under the grant, the indirect cost rate
applicable to each department/agency (including if the de minimis rate is used per
2 CFR §200.414(f)), and the type of direct cost base to which the rate will be
applied (for example, Modified Total Direct Costs (MTDC)). Do not include
indirect cost rates for subrecipients.
(c) In addition to the conditions contained on form HUD 7082, the grantee
shall comply with requirements established by the Office of
Management and Budget (OMB) concerning the Dun and Bradstreet
Data Universal Numbering System (DUNS); the System for Award
Management (SAM.gov.); the Federal Funding Accountability and
Transparency Act as provided in 2 CFR part 25, Universal Identifier and
General Contractor Registration; and 2 CFR part 170, Reporting
Subaward and Executive Compensation Information.
(d) The grantee shall ensure that no CDBG funds are used to support any
Federal, State, or local projects that seek to use the power of eminent
domain, unless eminent domain is employed only for a public use. For
the purposes of this requirement, public use shall not be construed to
include economic development that primarily benefits private
entities. Any use of funds for mass transit, railroad, airport, seaport or
highway projects as well as utility projects which benefit or serve the
general public (including energy-related, communication -related, water -
related and wastewater -related infrastructure), other structures
designated for use by the general public or which have other common -
carrier or public -utility functions that serve the general public and are
subject to regulation and oversight by the government, and projects for
the removal of an immediate threat to public health and safety or
brownfield as defined in the Small Business Liability Relief and
Brownfields Revitalization Act (Public Law 107-118) shall be
considered a public use for purposes of eminent domain.
(e) The Grantee or unit of general local government that directly or
indirectly receives CDBG funds may not sell, trade, or otherwise
transfer all or any such portion of such funds to another such entity in
exchange for any other funds, credits or non -Federal considerations, but
must use such funds for activities eligible under title I of the Act.
(f) E.O. 12372 -Special Contract Condition - Notwithstanding any other
provision of this agreement, no funds provided under this .agreement
may be obligated or expended for the planning or construction of water
or sewer facilities until receipt of written notification from HUD of the
release of funds on completion of the review procedures required under
Executive Order (E.O.) 12372, Intergovernmental Review of Federal
Programs, and HUD's implementing regulations at 24 CFR Part 52. The
recipient shall also complete the review procedures required under E.O.
12372 and 24 CFR Part 52 and receive written notification from HUD of
the release of funds before obligating or expending any funds provided
under this agreement for any new or revised activity for the planning or
construction of water or sewer facilities not previously reviewed under
E.O. 12372 and implementing regulations.
(g)
CDBG funds may not be provided to a for-profit entity pursuant to
section 105(a)(17) of the Act unless such activity or project has been
evaluated and selected in accordance with Appendix A to 24 CFR 570 -
"Guidelines and Objectives for Evaluating Project Costs and Financial
Requirements." (Source - P.L. 113-235, Consolidated and Further
Continuing Appropriations Act, 2015, Division K, Title II, Community
Development Fund).
Funding Approval and HOME
Investment Partnerships Agreement
Title II of the National Affordable Housing Act
U.S. Department of Housing and Urban Development
Office of Community Planning and Development
1. Participant Name and Address
4/Ty DF at,E4 4)41F4,t=/.1).L4O4
Po Box 4748
Clearwater, FL 33758-4748
6. Previous Obligation (Enter "0" for initial FY allocation)
a. Formula Funds
b. Community Housing Development Org. (CHDO) Competitive
7. Current Transaction (+ or -)
a. Formula Funds
1. CHDO (For deobligations only)
2. Non- CHDO (For deobligations only)
b. CHDO Competitive Reallocation or Deobligation
8. Revised Obligation
a. Formula Funds
b. CHDO Competitive Reallocation
9. Special Conditions (check applicable box)
El Not applicable 0 Attached
2. Grant Number: M18-MC120230
3a Tax Identification Number:
596000289
3b. Unique Entity Identifier (formerly
DUNS): 078307303
4. Appropriation Number
86 8/1 0205
$383,146.00
$383,146.00
5. FY (yyyy)
2018
10. Date of Obligation (Congressional Release Date)
(mm/dd/yyyy): 10/03/2018
11. Indirect Cost Rate*
Administering Agency/Dept.
Indirect Cost Rate
%
Direct Cost Base
12. Period of Performance:
Date in Box #10 - 09/01/2026
* If funding assistance will be used for payment of indirect costs pursuant to 2 CFR
200, Subpart E -Cost Principles, provide the name of the department/agency, its
indirect cost rate (including if the de minimis rate is charged per 2 § CFR 200.414), and
the direct cost base to which the rate will be applied. Do not include cost rates for
subrecipients.
This Agreement between the Department of Housing and Urban Development (HUD) and the Participating Jurisdiction/Entity is made pursuant to the authority of the HOME
Investment Partnerships Act (42 U.S.C. 12701 et seq.). The Participating Jurisdiction's /Entity's approved Consolidated Plan submission/Application and the HUD regulations at 24
CFR Part 92 (as is now in effect and as may be amended from time to time) and this HOME Investment Partnership Agreement, form HUD -40093, including any special conditions,
constitute part of this Agreement. Subject to the provisions of this Agreement, HUD will make the funds for the Fiscal Year specified, available to the Participating Jurisdiction/Entity
upon execution of this Agreement by the parties. All funds for the specified Fiscal Year provided by HUD by formula reallocation are covered by this Agreement upon execution of
an amendment by HUD, without the Participating Jurisdiction's execution of the amendment or other consent. HUD's payment of funds under this Agreement is subject to the
Participating Jurisdiction's/Entity's compliance with HUD's electronic funds transfer and information reporting procedures issued pursuant to 24 CFR 92.502. To the extent authorized
by HUD regulations at 24 CFR Part 92, HUD may, by its execution of an amendment, deobligate funds previously awarded to the Participating Jurisdiction/Entity without the
Participating Jurisdiction's/Entity's execution of the amendment or other consent. The Participating Jurisdiction/Entity agrees that funds invested in affordable housing under 24
CFR Part 92 are repayable when the housing no longer qualifies as affordable housing. Repayment shall be made as specified in 24 CFR Part 92. The Participating Jurisdiction
agrees to assume all of the responsibility for environmental review, decision making, and actions, as specified and required in regulation at 24 CFR 92.352 and 24 CFR Part 58.
The Grantee shall comply with requirements established by the Office of Management and Budget (OMB) conceming the Universal Numbering System and System for Award
Management (SAM) requirements in Appendix A to 2 CFR part 25, and the Federal Funding Accountability and Transparency Act (FFATA) in Appendix A to 2 CFR part 170.
The Period of Performance for the funding assistance shall begin on the date specified in item 12 and shall end on September 1' of the 5'h fiscal year after the expiration of the
period of availability for obligation. Funds remaining in the account will be cancelled and thereafter not available for obligation or expenditure for any purpose. Per 31 U.S.C. 1552.
The grantee shall not incur any obligations to be paid with such assistance after the end of the Period of Performance.
13. For the U.S. Department of HUD (Name and Title of Authorized Official) 14. 15. Date
Tom Bilodeau, HUD Community Planning and Development Program Manager 10/03/2018
16. For the Participating Jurisdiction/Entity (Name and Title of Authorized Official)
W/t1-i*u 6. Ai 444E, C/tv 441Y4iEL-
19. Check one:
Initial Agreement
20. Funding Information: HOME
Source of Funds Appropriation Code
2018 86 8/1 0205
2017 86 7/0 0205
2016 86 6/9 0205
17. S. ature
18. Date
i ° /23/ 2.0�
❑ Amendment #
PAS Code
HMF
HMF
HMF
Amount
$382,712.00
$ 113.00
$ 321.00
Page 1
form HUD -40093
Good Day,
U. S. Department of Housing and Urban Development
Jacksonville Field Office
CPD Division, 4HD
Charles Bennett Federal Building
400 West Bay Street, Suite 1015
Jacksonville, Florida 32202-4410
Please return these copies of the fully
executed, signed and dated Grant Agreements to
Kevin Chung at the below address.
The other signed copies are for your records.
Kevin P Chung
Financial Analyst
U.S. Department of Housing and Urban Development
Office of Community Planning and Development
400 West Bay Street, Suite 1015
Jacksonville, FL 32202
Phone: (904) 208-6116
Email: kevin.p.chung@hud.gov
HUD's mission is to increase homeownership, support community
development and increase access to affordable housing free from discrimination.
www.hud.gov espanol.hud.gov
Funding Approval/Agreement
Title I of the Housing and Community
Development Act (Public Law 930383)
HI -00515R of 20515R
U.S. Department of Housing and Urban Development
Office of Community Planning and Development
Community Development Block Grant Program
OMB Approval No. 2506-0193
exp 5/31/2018
1. Name of Grantee (as shown in item 5 of Standard Form 424)
CITY of C44044&41iL fhatio
2. Grantee's Complete Address (as shown in item 5 of Standard Form 424)
PO Box 4748
Clearwater, FL 33758-4748
3a. Grantee's 9 -digit Tax ID Number
596000289
3b. Grantee's 9 -digit DUNS Number
078307303
4. Date use of funds may begin
10/01/2018
5a. Project/Grant No. 1
B -18 -MC -12-0002
5b. Project/Grant No. 2
6a. Amount Approved
$740,943.00
6b. Amount Approved
Grant Agreement: This Grant Agreement between the Department of Housing and Urban Development (HUD) and the above named Grantee is made pursuant to the
authority of Title I of the Housing and Community Development Act of 1974, as amended, (42 USC 5301 et seq.). The Grantee's submissions for Title I assistance, the
HUD regulations at 24 CFR Part 570 (as now in effect and as may be amended from time to time), and this Funding Approval, including any special conditions, constitute
part of the Agreement. Subject to the provisions of this Grant Agreement, HUD will make the funding assistance specified here available to the Grantee upon execution
of the Agreement by the parties. The funding assistance specified in the Funding Approval may be used to pay costs incurred after the date specified in item 4 above
provided the activities to which such costs are related are carried out in compliance with all applicable requirements. Pre -agreement costs may not be paid with funding
assistance specified here unless they are authorized in HUD regulations or approved by waiver and listed in the special conditions to the Funding Approval. The Grantee
agrees to assume all of the responsibilities for environmental review, decision making, and actions, as specified and required in regulations issued by the Secretary
pursuant to Section 104(g) of Title I and published in 24 CFR Part 58. The Grantee further acknowledges its responsibility for adherence to the Agreement by sub -
recipient entities to which it makes funding assistance hereunder available.
U.S. Department of Housing and Urban Development (By Name)
Tom Bilodeau
Grantee Name
CITY
Dft4L IZIOAT04,
Title
Program Manager
Title Fs'P+G D4
G /7 bl 6t 8 4 4 6.54.
Signature i
• ,
Date (mm/dd/yyyy)
10/03/2018
Signature
lia(20:40tA es • 1411446.
Date (mm/dd/yyyy)
7. Category of Title I Assistance for this Funding Action:
Entitlement, Sec 106(b)
8. Special Conditions
(check one)
1 None
9a. Date HUD Received Submission
08/13/2018
10. check
one
Orig. Funding
Approval
Amendment
Amendment Number
0 a.
9b. Date Grantee Notified
10/03/2018
0 Attached
• b.
9c. Date of Start of Program Year
(10/01/2018)
11. Amount of Community Development
Block Grant
FY (2018)
$740,885.00
FY (2017)
$ 58.00
FY ( )
a. Funds Reserved for this Grantee
b. Funds now being Approved
c. Reservation to be Cancelled
(11a minus 11b)
12a. Amount of Loan Guarantee Commitment now being Approved
N/A
12b. Name and complete Address of Public Agency
C i>'y
DA' Ot.84B4.r6rG/ ,"'‘..4,14,/, 4
PO Box 4748
Clearwater, FL 33758-4748
Loan Guarantee Acceptance Provisions for Designated Agencies:
The public agency hereby accepts the Grant Agreement executed by the
Department of Housing and Urban Development on the above date with
respect to the above grant number(s) as Grantee designated to receive loan
guarantee assistance, and agrees to comply with the terms and conditions
of the Agreement, applicable regulations, and other requirements of HUD
now or hereafter in effect, pertaining to the assistance provided it.
12c. Name of Authorized Official for Designated Public Agency
414
Title
Signature
HUD Accounting use Only
Batch TAC Program Y A Reg Area Document No. Project Number Category
1
5
3
1
7
6
Project Number
Project Number
Amount
Amount
Amount
Effective Date
(mm/dd/yyyy) F
Date Entered PAS (mm/dd/yyyy)
Date Entered LOCCS (mm/dd/yyyy)
Batch Number
Transaction Code
Entered By
Verified By
24 CFR 570
form HUD -7082 (5/15)
`L
8. Special Conditions.
(a) The period of performance for the funding assistance specified in the
Funding Approval ("Funding Assistance") shall begin on the date
specified in item 4 and shall end on September 1, 2025. The Grantee
shall not incur any obligations to be paid with such assistance after
September 1, 2025.
(b) The Recipient shall attach a schedule of its indirect cost rate(s) in the
format set forth below to the executed Agreement that is returned to
HUD. The Recipient shall provide HUD with a revised schedule when
any change is made to the rate(s) described in the schedule. The
schedule and any revisions HUD receives from the Recipient shall be
incorporated herein and made a part of this Agreement, provided that the
rate(s) described comply with 2 CFR part 200, subpart E.
Administering Direct
Department/Agency Indirect cost rate Cost Base
%
%
%
Instructions: The Recipient must identify each agency or department of the
Recipient that will carry out activities under the grant, the indirect cost rate
applicable to each department/agency (including if the de minimis rate is used per
2 CFR §200.414(f)), and the type of direct cost base to which the rate will be
applied (for example, Modified Total Direct Costs (MTDC)). Do not include
indirect cost rates for subrecipients.
(c) In addition to the conditions contained on form HUD 7082, the grantee
shall comply with requirements established by the Office of
Management and Budget (OMB) concerning the Dun and Bradstreet
Data Universal Numbering System (DUNS); the System for Award
Management (SAM.gov.); the Federal Funding Accountability and
Transparency Act as provided in 2 CFR part 25, Universal Identifier and
General Contractor Registration; and 2 CFR part 170, Reporting
Subaward and Executive Compensation Information.
(d) The grantee shall ensure that no CDBG funds are used to support any
Federal, State, or local projects that seek to use the power of eminent
domain, unless eminent domain is employed only for a public use. For
the purposes of this requirement, public use shall not be construed to
include economic development that primarily benefits private
entities. Any use of funds for mass transit, railroad, airport, seaport or
highway projects as well as utility projects which benefit or serve the
general public (including energy-related, communication -related, water -
related and wastewater -related infrastructure), other structures
designated for use by the general public or which have other common -
carrier or public -utility functions that serve the general public and are
subject to regulation and oversight by the government, and projects for
the removal of an immediate threat to public health and safety or
brownfield as defined in the Small Business Liability Relief and
Brownfields Revitalization Act (Public Law 107-118) shall be
considered a public use for purposes of eminent domain.
(e) The Grantee or unit of general local government that directly or
indirectly receives CDBG funds may not sell, trade, or otherwise
transfer all or any such portion of such funds to another such entity in
exchange for any other funds, credits or non -Federal considerations, but
must use such funds for activities eligible under title I of the Act.
(f) E.O. 12372 -Special Contract Condition - Notwithstanding any other
provision of this agreement, no funds provided under this .agreement
may be obligated or expended for the planning or construction of water
or sewer facilities until receipt of written notification from HUD of the
release of funds on completion of the review procedures required under
Executive Order (E.O.) 12372, Intergovernmental Review of Federal
Programs, and HUD's implementing regulations at 24 CFR Part 52. The
recipient shall also complete the review procedures required under E.O.
12372 and 24 CFR Part 52 and receive written notification from HUD of
the release of funds before obligating or expending any funds provided
under this agreement for any new or revised activity for the planning or
construction of water or sewer facilities not previously reviewed under
E.O. 12372 and implementing regulations.
(g)
CDBG funds may not be provided to a for-profit entity pursuant to
section 105(a)(17) of the Act unless such activity or project has been
evaluated and selected in accordance with Appendix A to 24 CFR 570 -
"Guidelines and Objectives for Evaluating Project Costs and Financial
Requirements." (Source - P.L. 113-235, Consolidated and Further
Continuing Appropriations Act, 2015, Division K, Title II, Community
Development Fund).
Funding Approval and HOME
Investment Partnerships Agreement
Title II of the National Affordable Housing Act
U.S. Department of Housing and Urban Development
Office of Community Planning and Development
1. Participant Name and Address
C 1 TV OF 04.044 0011.4 4, F404 AIM
Po Box 4748
Clearwater, FL 33758-4748
2. Grant Number: M18-MC120230
3a Tax Identification Number:
596000289
3b. Unique Entity Identifier (formerly
DUNS): 078307303
4. Appropriation Number
86 8/1 0205
5. POW')
2018
6. Previous Obligation (Enter "0" for initial FY allocation)
a. Formula Funds
b. Community Housing Development Org. (CHDO) Competitive
7. Current Transaction (+ or -)
a. Formula Funds
1. CHDO (For deobligations only)
2. Non- CHDO (For deobligations only)
b. CHDO Competitive Reallocation or Deobligation
8. Revised Obligation
a. Formula Funds
b. CHDO Competitive Reallocation
9. Special Conditions (check applicable box)
El Not applicable 0 Attached
10. Date of Obligation (Congressional Release Date)
(mm/dd/yyyy): 10/03/2018
11. Indirect Cost Rate*
Administering Agency/Dept.
Indirect Cost Rate
%
%
%
Direct Cost Base
12. Period of Performance:
Date in Box #10 - 09/01/2026
* If funding assistance will be used for payment of indirect costs pursuant to 2 CFR
200, Subpart E -Cost Principles, provide the name of the department/agency, its
indirect cost rate (including if the de minimis rate is charged per 2 § CFR 200.414), and
the direct cost base to which the rate will be applied. Do not include cost rates for
subrecipients.
This Agreement between the Department of Housing and Urban Development (HUD) and the Participating Jurisdiction/Entity is made pursuant to the authority of the HOME
Investment Partnerships Act (42 U.S.C. 12701 et seq.). The Participating Jurisdiction's /Entity's approved Consolidated Plan submission/Application and the HUD regulations at 24
CFR Part 92 (as is now in effect and as may be amended from time to time) and this HOME Investment Partnership Agreement, form HUD -40093, including any special conditions,
constitute part of this Agreement. Subject to the provisions of this Agreement, HUD will make the funds for the Fiscal Year specified, available to the Participating Jurisdiction/Entity
upon execution of this Agreement by the parties. All funds for the specified Fiscal Year provided by HUD by formula reallocation are covered by this Agreement upon execution of
an amendment by HUD, without the Participating Jurisdiction's execution of the amendment or other consent. HUD's payment of funds under this Agreement is subject to the
Participating Jurisdiction's/Entity's compliance with HUD's electronic funds transfer and information reporting procedures issued pursuant to 24 CFR 92.502. To the extent authorized
by HUD•regulations at 24 CFR Part 92, HUD may, by its execution of an amendment, deobligate funds previously awarded to the Participating Jurisdiction/Entity without the
Participating Jurisdiction's/Entity's execution of the amendment or other consent. The Participating Jurisdiction/Entity agrees that funds invested in affordable housing under 24
CFR Part 92 are repayable when the housing no longer qualifies as affordable housing. Repayment shall be made as specified in 24 CFR Part 92. The Participating Jurisdiction
agrees to assume all of the responsibility for environmental review, decision making, and actions, as specified and required in regulation at 24 CFR 92.352 and 24 CFR Part 58.
The Grantee shall comply with requirements established by the Office of Management and Budget (OMB) conceming the Universal Numbering System and System for Award
Management (SAM) requirements in Appendix A to 2 CFR part 25, and the Federal Funding Accountability and Transparency Act (FFATA) in Appendix A to 2 CFR part 170.
The Period of Performance for the funding assistance shall begin on the date specified in item 2 and shall end on September 1' of the 5'h fiscal year after the expiration of the
period of availability for obligation. Funds remaining in the account will be cancelled and thereafter not available for obligation or expenditure for any purpose. Per 31 U.S.C. 1552.
The grantee shall not incur any obligations to be paid with such assistance after the end of the Period of Performance.
13. For the U.S. Department of HUD (Name and Title of Authorized Official)
Tom Bilodeau, HUD Community Planning and Development Program Manager
15. Date
10/03/2018
16. For the Participating Jurisdiction/Entity (Name and Title of Authorized Official)
&dLL.1,+.ic 6,1,D<de,/// airy 4r *no 446=14.
19. Check one:
® Initial Agreement ❑ Amendment #
20. Funding Information: HOME
Source of Funds Appropriation Code
2018
2017
2016
86 8/1 0205
86 7/0 0205
86 6/9 0205
PAS Code
HMF
HMF
HMF
17. Si ature 18. Date
/a /23/zix$
Amount
$382,712.00
$ 113.00
$ 321.00
Page 1
form HUD -40093
APPENDIX A
Introduction
This appendix consists of Section 105(a) of the Housing and
Community Development Act of 1974 (HCDA). Because the Eligible
Activities section of the State CDBG regulations (refer to 570.482 in
Appendix B) are minimal, the states must use HCDA as the primary
authority for determining eligibility of potential state CDBG activities.
HCDA Section Eligible Activities
1O5(a)
Section 105(a) Activities assisted under this title may include only—
Section
1O5(a)(1)
(1) the acquisition of real property (including air rights, water rights,
and other interests therein) which is
(A) blighted, deteriorated, deteriorating, undeveloped, or
inappropriately developed from the standpoint of sound community
development and growth;
(B) appropriate for rehabilitation or conservation activities;
(C) appropriate for the preservation or restoration of historic sites, the
beautification of urban land, the conservation of open spaces, natural
resources, and scenic areas, the provision of recreational
opportunities, or the guidance of urban development;
(D) to be used for the provision of public works, facilities, and
improvements eligible for assistance under this title; or
(E) to be used for other public purposes
State Community Development Block Grant Program Appendix A ❖ 1
Section
105(a)(2)
Section
105(a)(3)
Section
105(a)(4)
Section
105(a)(5)
Section
105(a)(6)
Section
105(a)(7)
Section
105(a)(8)
(2) the acquisition, construction, reconstruction, or installation
(including design features and improvements with respect to such
construction, reconstruction, or installation that promote energy
efficiency) of public works, facilities (except for buildings for the
general conduct of government), and site or other improvements;
(3) code enforcement in deteriorated or deteriorating areas in which
such enforcement, together with public or private improvements or
services to be provided, may be expected to arrest the decline of the
area;
(4) clearance, demolition, removal, reconstruction, and rehabilitation
(including rehabilitation which promotes energy efficiency) of buildings
and improvements (including interim assistance, and financing public or
private acquisition for reconstruction or rehabilitation, and
reconstruction or rehabilitation, of privately owned properties, and
including the renovation of closed school buildings);
(5) special projects directed to the removal of material and architectural
barriers which restrict the mobility and accessibility of elderly and
handicapped persons;
(6) payments to housing owners for losses of rental income incurred in
holding for temporary periods housing units to be utilized for the
relocation of individuals and families displaced by activities under this
title;
(7) disposition (through sale, lease, donation, or otherwise) of any real
property acquired pursuant to this title or its retention for public
purposes;
(8) provision of public services, including but not limited to those
concerned with employment, crime prevention, child care, health, drug
abuse, education, energy conservation, welfare or recreation needs, if
such services have not been provided by the unit of general local
government (through funds raised by such unit, or received by such unit
from the State in which it is located) during any part of the twelve-
month period immediately preceding the date of submission of the
statement with respect to which funds are to be made available under
this title, and which are to be used for such services, unless the
Secretary finds that the discontinuation of such services was the result
of events not within the control of the unit of general local government,
2 ❖ Appendix A State Community Development Block Grant Program
Section
105(a)(9)
Section
105(a)(10)
Section
105(a)(11)
Section
105(a)(12)
except that not more than 15 per centum of the amount of any assistance
to a unit of general local government (or in the case of nonentitled
communities not more than 15 per centum statewide) under this title
including program income may be used for activities under this
paragraph unless such unit of general local government used more than
15 percent of the assistance received under this title for fiscal year 1982
or fiscal year 1983 for such activities (excluding any assistance received
pursuant to Public Law 98-8), in which case such unit of general local
government may use not more than the percentage or amount of such
assistance used for such activities for such fiscal year, whichever
method of calculation yields the higher amount, except that of any
amount of assistance under this title (including program income) in each
of fiscal years 1993 through 2000 to the City of Los Angeles and
County of Los Angeles, each such unit of general government may use
not more than 25 percent in each such fiscal year for activities under
this paragraph, and except that of any amount of assistance under this
title (including program income) in each of the fiscal years 1999, 2000,
and 2001, to the City of Miami, such city may use not more than 25
percent in each fiscal year for activities under this paragraph;
(9) payment of the non -Federal share required in connection with a
Federal grant-in-aid program undertaken as part of activities assisted
under this title;
(10) payment of the cost of completing a project funded under title 1I
of the Housing Act of 1949;
(11) relocation payments and assistance for displaced individuals,
families, businesses, organizations, and farm operations, when
determined by the grantee to be appropriate;
(12) activities necessary
(A) to develop a comprehensive community development plan, and
(B) to develop a policy -planning -management capacity so that the
recipient of assistance under this title may more rationally and
effectively
(i) determine its needs,
(ii) set long-term goals and short-term objectives,
(iii) devise programs and activities to meet these goals and
State Community Development Block Grant Program Appendix A ❖ 3
Section
105(a)(13)
Section
105(a)(14)
objectives,
(iv) evaluate the progress of such programs in accomplishing these
goals and objectives, and
(v) carry out management, coordination, and monitoring of
activities necessary for effective planning implementation;
(13) payment of reasonable administrative costs related to establishing
and administering federally approved enterprise zones and payment of
reasonable administrative costs and carrying charges related to
(A) administering the HOME program under title II of the Cranston -
Gonzalez National Affordable Housing Act; and
(B) the planning and execution of community development and
housing activities, including the provision of information and
resources to residents of areas in which community development and
housing activities are to be concentrated with respect to the planning
and execution of such activities, and including the carrying out of
activities as described in section 701(e) of the Housing Act of 1954
on the date prior to the date of enactment of the Housing and
Community Development Amendments of 1981;
(14) provision of assistance including loans (both interim and long-
term) and grants for activities which are carried out by public or private
nonprofit entities, including
(A) acquisition of real property;
(B) acquisition, construction, reconstruction, rehabilitation, or
installation of
(i) public facilities (except for buildings for the general conduct of
government), site improvements, and utilities, and
(ii) commercial or industrial buildings or structures and other
commercial or industrial real property improvements; and
(C) planning;
4 ❖ Appendix A State Community Development Block Grant Program
Section
1O5(a)(15)
Section
1O5(a)(16)
Section
1O5(a)(17)
(15) assistance to neighborhood -based nonprofit organizations, local
development corporations, nonprofit organizations serving the
development needs of the communities in nonentitlement areas, or
entities organized under section 301(d) of the Small Business
Investment Act of 1958 to carry out a neighborhood revitalization or
community economic development or energy conservation project in
furtherance of the objectives of section 101(c) of this title, and
assistance to neighborhood -based nonprofit organizations, or other
private or public nonprofit organizations, for the purpose of assisting, as
part of neighborhood revitalization or other community development,
the development of shared housing opportunities (other than by
construction of new facilities) in which elderly families (as defined in
section 3(b)(3) of the United States Housing Act of 1937) benefit as a
result of living in a dwelling in which the facilities are shared with
others in a manner that effectively and efficiently meets the housing
needs of the residents and thereby reduces their cost of housing;
(16) activities necessary to the development of energy use strategies
related to a recipient's development goals, to assure that those goals are
achieved with maximum energy efficiency, including items such as—
(A) an analysis of the manner in, and the extent to, which energy
conservation objectives will be integrated into local government
operations, purchasing and service delivery, capital improvements
budgeting, waste management, district heating and cooling, land use
planning and zoning, and traffic control, parking, and public
transportation functions; and
(B) a statement of the actions the recipient will take to foster energy
conservation and the use of renewable energy resources in the private
sector, including the enactment and enforcement of local codes and
ordinances to encourage or mandate energy conservation or use of
renewable energy resources, financial and other assistance to be
provided (principally for the benefit of low- and moderate -income
persons) to make energy conserving improvements to residential
structures, and any other proposed energy conservation activities;
(17) provision of assistance to private, for-profit entities, when the
assistance is appropriate to carry out an economic development project
(that shall minimize, to the extent practicable, displacement of existing
businesses and jobs in neighborhoods) that—
(A) creates or retains jobs for low- and moderate -income persons;
State Community Development Block Grant Program Appendix A ❖ 5
Section
105(a)(18)
Section
105(a)(19)
Section
105(a)(20)
Section
105(a)(21)
Section
105(a)(22)
(B) prevents or eliminates slums and blight;
(C) meets urgent needs;
(D) creates or retains businesses owned by community residents;
(E) assists businesses that provide goods or services needed by, and
affordable to, low- and moderate -income residents; or
(F) provides technical assistance to promote any of the activities
under subparagraphs (A) through (E);
(18) the rehabilitation or development of housing assisted under Section
17 of the United States Housing Act of 1937;
(19) provision of technical assistance to public or nonprofit entities to
increase the capacity of such entities to carry out eligible neighborhood
revitalization or economic development activities, which assistance
shall not be considered a planning cost as defined in paragraph (12) or
administrative cost as defined in paragraph (13);
(20) housing services, such as housing counseling, in connection with
tenant -based rental assistance and affordable housing projects assisted
under title II of the Cranston -Gonzalez National Affordable Housing
Act, energy auditing, preparation of work specifications, loan
processing, inspections, tenant selection, management of tenant -based
rental assistance, and other services related to assisting owners, tenants,
contractors, and other entities, participating or seeking to participate in
housing activities assisted under title II of the Cranston -Gonzalez
National Affordable Housing Act;
(21) provision of assistance by recipients under this title to institutions
of higher education having a demonstrated capacity to carry out eligible
activities under this subsection for carrying out such activities;
(22) provision of assistance to public and private organizations,
agencies, and other entities (including nonprofit and for-profit entities)
to enable such entities to facilitate economic development by -
6 ❖ Appendix A State Community Development Block Grant Program
Section
1O5(a)(23)
Section
1O5(a)(24)
(A) providing credit (including providing direct loans and loan
guarantees, establishing revolving loan funds, and facilitating peer
lending programs) for the establishment, stabilization, and expansion of
microenterprises;
(B) providing technical assistance, advice, and business support
services (including assistance, advice, and support relating to
developing business plans, securing funding, conducting marketing,
and otherwise engaging in microenterprise activities) to owners of
microenterprises and persons developing microenterprises; and
(C) providing general support (such as peer support programs and
counseling) to owners of microenterprises and persons developing
microenterprises;
(23) activities necessary to make essential repairs and to pay operating
expenses necessary to maintain the habitability of housing units
acquired through tax foreclosure proceedings in order to prevent
abandonment and deterioration of such housing in primarily low- and
moderate -income neighborhoods;
(24) provision of direct assistance to facilitate and expand
homeownership among persons of low and moderate income (except
that such assistance shall not be considered a public service for purposes
of paragraph (8)) by using such assistance to—
(A) subsidize interest rates and mortgage principal amounts for low -
and moderate -income homebuyers;
(B) finance the acquisition by low- and moderate -income
homebuyers of housing that is occupied by the homebuyers;
(C) acquire guarantees for mortgage financing obtained by low- and
moderate -income homebuyers from private lenders (except that
amounts received under this title may not be used under this
subparagraph to directly guarantee such mortgage financing and
grantees under this title may not directly provide such guarantees);
(D) provide up to 50 percent of any downpayment required from low -
or moderate -income homebuyer; or
(E) pay reasonable closing costs (normally associated with the
purchase of a home) incurred by low- or moderate -income
homebuyers; and
State Community Development Block Grant Program Appendix A ❖ 7
Section
1O5(a)(25)
(25) lead-based paint hazard evaluation and reduction, as defined in
section 1004 of the Residential Lead -Based Paint Hazard Reduction Act
of 1992.
8 ❖ Appendix A State Community Development Block Grant Program
10/11/2018
24 CFR Appendix A to Part 570, Guidelines and Objectives for Evaluating Project Costs and Financial Requirements I US Law I LII / Le...
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CFR > Title 24 > Subtitle B > Chapter V > Subchapter C > Part 570 > Subpart 0 > Appendix A tojart_570
24 CFR Appendix A to Part 570, Guidelines and Objectives for
Evaluating Project Costs and Financial Requirements
Appendix A to Part 570 - Guidelines and Objectives for Evaluating Project Costs and
Financial Requirements
I. Guidelines and Objectives for Evaluating Project Costs and Financial Requirements. HUD has
developed the following guidelines that are designed to provide the recipient with a framework for
financially underwriting and selecting CDBG-assisted economic development projects which are
financially viable and will make the most effective use of the CDBG funds. The use of these
underwriting guidelines as published by HUD is not mandatory. However, grantees electing not to
use these underwriting guidelines would be expected to conduct basic financial underwriting prior
to the provision of CDBG financial assistance to a for-profit business. States electing not to use
these underwriting guidelines would be expected to ensure that the state or units of general local
government conduct basic financial underwriting prior to the provision of CDBG financial
assistance to a for-profit business.
II. Where appropriate, HUD's underwriting guidelines recognize that different levels of review are
appropriate to take into account differences in the size and scope of a proposed project, and in the
case of a microenterprise or other small business to take into account the differences in the
capacity and level of sophistication among businesses of differing sizes.
III. Recipients are encouraged, when they develop their own programs and underwriting criteria, to
also take these factors into account. For example, a recipient administering a program providing
only technical assistance to small businesses might choose to apply underwriting guidelines to the
technical assistance program as a whole, rather than to each instance of assistance to a business.
Given the nature and dollar value of such a program, a recipient might choose to limit its
evaluation to factors such as the extent of need for this type of assistance by the target group of
businesses and the extent to which this type of assistance is already available.
IV. The objectives of the underwriting guidelines are to ensure:
(1) that project costs are reasonable;
(2) that all sources of project financing are committed;
(3) that to the extent practicable, CDBG funds are not substituted for non -Federal financial
support;
(4) that the project is financially feasible;
(5) that to the extent practicable, the return on the owner's equity investment will not be
unreasonably high; and
4.4... .ii K7n
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10/11/2018 24 CFR Appendix A to Part 570, Guidelines and Objectives for Evaluating Project Costs and Financial Requirements I US Law LII / Le...
(6) that to the extent practicable, CDBG funds are disbursed on a pro rata basis with other
finances provided to the project.
i. Project costs are reasonable. i. Reviewing costs for reasonableness is important. It will help the
recipient avoid providing either too much or too little CDBG assistance for the proposed project.
Therefore, it is suggested that the grantee obtain a breakdown of all project costs and that each
cost element making up the project be reviewed for reasonableness. The amount of time and
resources the recipient expends evaluating the reasonableness of a cost element should be
commensurate with its cost. For example, it would be appropriate for an experienced reviewer
looking at a cost element of less than $10,000 to judge the reasonableness of that cost based
upon his or her knowledge and common sense. For a cost element in excess of $10,000, it would
be more appropriate for the reviewer to compare the cost element with a third -party, fair -market
price quotation for that cost element. Third -party price quotations may also be used by a reviewer
to help determine the reasonableness of cost elements below $10,000 when the reviewer
evaluates projects infrequently or if the reviewer is less experienced in cost estimations. If a
recipient does not use third -party price quotations to verify cost elements, then the recipient would
need to conduct its own cost analysis using appropriate cost estimating manuals or services.
ii. The recipient should pay particular attention to any cost element of the project that will be
carried out through a non -arms -length transaction. A non -arms -length transaction occurs when the
entity implementing the CDBG assisted activity procures goods or services from itself or from
another party with whom there is a financial interest or family relationship. If abused, non -arms -
length transactions misrepresent the true cost of the project.
2. Commitment of all project sources of financing. The recipient should review all projected
sources of financing necessary to carry out the economic development project. This is to ensure
that time and effort is not wasted on assessing a proposal that is not able to proceed. To the extent
practicable, prior to the commitment of CDBG funds to the project, the recipient should verify that:
sufficient sources of funds have been identified to finance the project; all participating parties
providing those funds have affirmed their intention to make the funds available; and the
participating parties have the financial capacity to provide the funds.
3. Avoid substitution of CDBG funds for non -Federal financial support. i. The recipient should
review the economic development project to ensure that, to the extent practicable, CDBG funds
will not be used to substantially reduce the amount of non -Federal financial support for the activity.
This will help the recipient to make the most efficient use of its CDBG funds for economic
development. To reach this determination, the recipient's reviewer would conduct a financial
underwriting analysis of the project, including reviews of appropriate projections of revenues,
expenses, debt service and returns on equity investments in the project. The extent of this review
should be appropriate for the size and complexity of the project and should use industry standards
for similar projects, taking into account the unique factors of the project such as risk and location.
il. Because of the high cost of underwriting and processing loans, many private financial lenders
do not finance commercial projects that are less than $100,000. A recipient should familiarize itself
with the lending practices of the financial institutions in its community. If the project's total cost is
one that would normally fall within the range that financial institutions participate, then the recipient
should normally determine the following:
10/11/208 24 CFR Appendix A to Part 570, Guidelines and Objectives for Evaluating Project Costs and Financial Requirements I US Law I LII / Le...
A. Private debt financing - whether or not the participating private, for-profit business (or other
entity having an equity interest) has applied for private debt financing from a commercial lending
institution and whether that institution has completed all of its financial underwriting and loan
approval actions resulting in either a firm commitment of its funds or a decision not to participate in
the project; and
B. Equity participation - whether or not the degree of equity participation is reasonable given
general industry standards for rates of return on equity for similar projects with similar risks and
given the financial capacity of the entrepreneur(s) to make additional financial investments.
iii. If the recipient is assisting a microenterprise owned by a low- or moderate -income person(s), in
conducting its review under this paragraph, the recipient might only need to determine that non -
Federal sources of financing are not available (at terms appropriate for such financing) in the
community to serve the low- or moderate -income entrepreneur.
4. Financial feasibility of the project. i. The public benefit a grantee expects to derive from the
CDBG assisted project (the subject of separate regulatory standards) will not materialize if the
project is not financially feasible. To determine if there is a reasonable chance for the project's
success, the recipient should evaluate the financial viability of the project. A project would be
considered financially viable if all of the assumptions about the project's market share, sales
levels, growth potential, projections of revenue, project expenses and debt service (including
repayment of the CDBG assistance if appropriate) were determined to be realistic and met the
project's break-even point (which is generally the point at which all revenues are equal to all
expenses). Generally speaking, an economic development project that does not reach this break-
even point over time is not financially feasible. The following should be noted in this regard:
A. some projects make provisions for a negative cash flow in the early years of the project while
space is being leased up or sales volume built up, but the project's projections should take these
factors into account and provide sources of financing for such negative cash flow; and
B. it is expected that a financially viable project will also project sufficient revenues to provide a
reasonable return on equity investment. The recipient should carefully examine any project that is
not economically able to provide a reasonable return on equity investment. Under such
circumstances, a business may be overstating its real equity investment (actual costs of the
project may be overstated as well), or it may be overstating some of the project's operating
expenses in the expectation that the difference will be taken out as profits, or the business may be
overly pessimistic in its market share and revenue projections and has downplayed its profits.
ii. In addition to the financial underwriting reviews carried out earlier, the recipient should evaluate
the experience and capacity of the assisted business owners to manage an assisted business to
achieve the projections. Based upon its analysis of these factors, the recipient should identify
those elements, if any, that pose the greatest risks contributing to the project's lack of financial
feasibility.
5. Return on equity investment. To the extent practicable, the CDBG assisted activity should
provide not more than a reasonable return on investment to the owner of the assisted activity. This
will help ensure that the grantee is able to maximize the use of its CDBG funds for its economic
development objectives. However, care should also be taken to avoid the situation where the
owner is likely to receive too small a return on his/her investment, so that his/her motivation
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10/11/2018 24 CFR Appendix A to Part 570, Guidelines and Objectives for Evaluating Project Costs and Financial Requirements I US Law 1 LII / Le...
remains high to pursue the business with vigor. The amount, type and terms of the CDBG
assistance should be adjusted to allow the owner a reasonable return on his/her investment given
industry rates of return for that investment, local conditions and the risk of the project.
6. Disbursement of CDBG funds on a pro rata basis. To the extent practicable, CDBG funds used
to finance economic development activities should be disbursed on a pro rata basis with other
funding sources. Recipients should be guided by the principle of not placing CDBG funds at
significantly greater risk than non-CDBG funds. This will help avoid the situation where it is learned
that a problem has developed that will block the completion of the project, even though all or most
of the CDBG funds going in to the project have already been expended. When this happens, a
recipient may be put in a position of having to provide additional financing to complete the project
or watch the potential loss of its funds if the project is not able to be completed. When the recipient
determines that it is not practicable to disburse CDBG funds on a pro rata basis, the recipient
should consider taking other steps to safeguard CDBG funds in the event of a default, such as
insisting on securitizing assets of the project.
[ 60 FR 1953, Jan. 5, 1995]
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